The campaign group United Against Nuclear Iran has called on ICANN to switch off internet access to Iran, due to an apparent misunderstanding of what it is ICANN does.

In a letter sent earlier this month and published yesterday, UANI told ICANN to “immediately cease and desist” from providing “ICANN/IANA access” to Iranian entities covered by US and EU sanctions.

The group is worried that these organizations are using the internet to help Iran with its goal of creating nuclear weapons.

The letter states:

Absent access to ICANN/IANA, the dictatorial regime of Iran would be severely impeded in pursuing its illegal and amoral activities. For each day that you knowingly continue to provide Iran sanction-designated persons and entities access to the worldwide web, ICANN/IANA will be increasingly complicit in the IRGC and Iranian regime’s nefarious behavior. ICANN/IANA must stop transacting with such Iranian entities and persons and deny them access to Unique Web Identifiers, and therefore, the worldwide web.”

The letter is stupid on so many levels it’s difficult to know where to begin.

It appears to assume that ICANN has the power and ability to shut down certain individual .ir and .com domain names, which are registered to and used by sanctioned entities.

Prominent sanction-designated Iranian entities have acquired .ir Unique Internet Identifiers from ICANN/IANA through the RIPE NCC. For example, Iran’s nuclear brain trust, Malek Ashtar University holds the http://www.mut.ac.ir/ address. Major Iranian banks, including the country’s central bank, maintain active websites (e.g. http://www.cbi.ir, http://www.bank-maskan.ir, http://www.bmi.ir and http://www.banksepah.ir). Further, Khatam al-Anbia, which serves as the IRGC’s engineering arm with over 812 subsidiaries and is heavily involved in the construction of the Qom/Fordow nuclear weapons facilities, holds the web address of http://www.khatam.com. These sanction-designated entities could not gain such web access without ICANN/IANA.

You’ll immediately notice that UANI seems to think that RIPE NCC hands out .ir addresses, which it does not. RIPE is a Regional Internet Registry that deals exclusively with IP address blocks.

ICANN doesn’t have the power to shut down individual domains either. It has powers over the root zone — top-level domains — not second-level domains in individual TLDs.

The .ir ccTLD is delegated to the Tehran-based Institute for Research in Fundamental Sciences, which is not sanctioned.

ICANN could, feasibly, shut down the whole of .ir, as long as Verisign and the US Department of Commerce — which have ultimate control over the root — played along, but that seems like overkill.

Is UANI asking ICANN to shut down the whole of the .ir space?

Apparently not. In fact, the group condemns censorship and appears to support the ability of regular Iranian citizens to access a free, unfettered internet. The letter states:

Unfortunately, ICANN/IANA and the Unique Internet Identifiers that it provides are misused by the sanction-designated Iranian entities and persons to facilitate their illicit operations, activities and communications including support for Iran’s rogue nuclear weapons program, Iran’s sponsorship of terrorism around the world, and the Iranian regimes brutal crackdown against its own people. Disturbingly, that crackdown includes the ruthless censorship of the Internet and other communication access, and the use of tracking technology to monitor, torture and kill freedom seeking dissidents.

…

Simply put, ICANN/IANA should not provide the internet communications means that the Iranian regime and the IRGC misuses to censor and deny Internet freedoms to its people, much less to support Iran’s illicit nuclear program or its sponsorship of terrorism.

A second, more or less identical letter (pdf) sent to RIPE NCC accused the organization of being the country-code manager for .ir, apparently based on a misunderstanding of this web page.

The RIPE NCC is in contact with the Dutch Ministry of Foreign Affairs to ensure that we operate in accordance with Dutch law and all applicable international sanctions. Our advice from the Ministry has been that the RIPE NCC is not in violation of these sanctions. However, we will investigate in cases where new information is provided to us and we will ensure that changing circumstances do not place the RIPE NCC in violation of sanctions.

UANI could have avoided embarrassing itself with a couple of phone calls, and I have to wonder why it did not.

Comments (1)

Besides legacy IP holders, which are in a legal limbo in most regions, all LIRs (as RIPE call the organizations with number resources from them) have legal contracts with RIPE NCC. So, if the organizations are on the sanctions list, UANI has a point.

And considering the shortage of IPv4 addresses, anything that is taken back at this point will probably never return, even if/when sanctions are lifted.